Memorandum of proof/proof chart.

Pleadings review–A–ensure that all necessary parties have been joined and properly named; and–B–consider any amendments required to pleadings, including whether the relief claimed is adequate.

Discovery matters–A–ensure that transcripts from examinations for discovery have been obtained;–B–ensure completion of undertakings from examinations for discovery;–C–consider whether any information given by your client on discovery should be corrected or updated; and–D–compile a list of discovery extracts to be read in at trial.

Non-expert witnesses–A–develop a list of witnesses to be called at trial;–B–interview or re-interview witnesses and determine availability for trial;–C–obtain summonses and serve on all witnesses, together with appropriate conduct money;–D–determine whether a notice to call the adverse party as a witness ought to be served; and–E–determine appropriate procedure to compel attendance of out-of-province witnesses.

Legal research–A–update legal research on the issues; and–B–prepare briefs of authorities intended to be relied upon at trial.

Experts–A–are any expert witnesses required?–B–serve expert reports in accordance with the Rules of the relevant jurisdiction.

Pre-trial notices–A–consider issuing requests to admit documents or facts;–B–ensure that responses have been made to any requests to admit which have been received; and–C–serve notices required under the relevant provincial Evidence Act in regard to proof of business records.

Trial brief–A–prepare brief of documents to be used at trial;–B–prepare counsel’s trial brief(s); and–C–prepare briefs of authorities.

Counsel preparation–A–opening statement;–B–examinations-in-chief;–C–cross-examinations;–D–argument on anticipated evidentiary and other procedural issues; and–E–closing argument.